The price list for related-party transactions is information that many FDI businesses and multinational corporations are particularly interested in when tax season approaches. This is especially true in the context of tax authorities intensifying inspections of related-party transactions. Decree 132/2020/ND-CP By applying modern data analysis tools, preparing standardized related-party transaction documentation is not only a compliance obligation but also a factor in protecting businesses from the risk of tax audits and assessments. This article will provide a detailed analysis of the 2026 related-party transaction service price list, industry benchmarking data costs, popular service packages on the market, and the legal risks businesses need to pay special attention to when choosing. related party transaction advisory unit.
The pressure of the 2026 tax filing season: A "survival" challenge for FDI enterprises.
With the 2026 tax season fast approaching, multinational corporations and FDI businesses in Vietnam are facing unprecedented pressure. The current situation shows that tax authorities are not only checking the completeness of documents but also delving into the economic nature of each transaction.
- Changes in Policy and Technology: New Regulations on Mechanisms Global Minimum Tax Rate (Pillar Two) And the tax authority's application of AI-powered risk management systems means that even minor errors are automatically detected. The "price list for related-party transactions" has become a top concern for businesses seeking legal security.
- Urgent deadline: As per regulations, the deadline for submission is... Related Party Transaction Information Declaration Form (Form No. 01) coincides with the corporate income tax settlement period (usually the last day of the third month from the end of the fiscal year). Delays in finding a service provider with reasonable but high-quality transfer pricing will lead to a data "collapse" at the last minute.
- Complex documentation: Proving "independence" in internal loan transactions, corporate management expenses, or intellectual property rights requires an extremely accurate and up-to-date benchmarking data system, relevant to the year 2026.
See details: Deadline for submitting Related Party Transaction Documents
The consequences of "Cheap and Low-Quality" transfer pricing services.“
To optimize operating costs, many chief accountants or financial directors often prioritize providers offering extremely low transfer pricing rates. However, behind the low fees lie potential risks that could damage a company's reputation:
"Junk" benchmarking data“
Low-cost providers often don't invest in acquiring licenses for international databases like Orbis or Thomson Reuters. Instead, they use outdated data, data that is functionally incompatible (for example, comparing a manufacturing company with a company that owns core technology). When tax inspectors investigate, these comparisons will be completely rejected.
The document lacks economic logic.
A set of "copy-paste" documents from different industries will fail to explain the corporation's value chain. This raises suspicions with the tax authorities about profit shifting abroad, leading to the company being assigned the highest profit margin within its industry framework.
“"Losing money and suffering consequences" and severe penalties.
The difference between one related party transaction advisory services Professional and inexpensive services costing only a few tens of millions of dong can have significant financial consequences if audited, potentially amounting to billions of dong, or even leading to tax assessments.
Details of penalties and legal risks
Businesses should pay particular attention to the following penalties and legal consequences if they violate regulations on related-party transactions:
Penalties for administrative procedures
Based on Decree 125/2020/ND-CP Regarding administrative penalties for tax and invoice violations, errors in form and deadlines for submitting documents will be subject to the following specific penalties:
- Failure to submit the Related Party Transaction Appendix or late submission: Fines ranging from VND 8,000,000 to VND 25,000,000 (depending on the length of the delay).
- Submitting a declaration with incorrect or incomplete information: Fines range from VND 5,000,000 to VND 8,000,000.
Consequences of tax assessment
This is considered the worst-case scenario for any FDI enterprise. When the economic arguments in the dossier are not convincing enough or the comparative data is rejected, the Tax Authority will take the initiative in determining the enterprise's tax obligations through the following methods:
- Right to directly determine transfer pricing: If a business fails to provide transfer pricing documentation or the documentation is substandard, the tax authority has the right to directly determine the price, profit margin, or profit allocation ratio for the business.
- Choosing an unfavorable margin: Typically, the assessment will be based on the median or even the highest level within the industry's range (Quartile 3), causing the corporate income tax payable to skyrocket compared to the initial self-declared figures.
Late payment penalty
Besides the principal tax arrears, businesses also face financial burdens arising from delays in fulfilling their tax obligations, specifically:
- The penalty for late payment is 0.031 TP3T/day on the amount of tax to be collected. This is an extremely large cumulative amount if the audit lasts for many years.
Example: Company A was subject to a tax audit for the period 2022-2024 in 2026. The tax authorities rejected the audit and demanded the recovery of VND 5 billion in corporate income tax.
- Number of days overdue (assuming average): 730 days.
- Late payment penalty: 5 billion x 0.03% x 730 days = 1.095 billion VND.
- Total amount the business must pay additionally: 5 billion VND (principal) + 1.095 billion VND (late payment) = 6.095 billion VND
It is clear that, from simple administrative errors to violations of the nature of related-party transactions, businesses not only lose the tax revenue they would have been entitled to but also face the risk of being found guilty of tax fraud. Being fined 1 to 3 times the amount of tax evaded is not only a severe financial blow but also marks the end of a business's reputation in the tax authorities' risk assessment system for many years to come.
Solution: Professional transfer pricing services
MAN – Master Accountant Network provides comprehensive solutions focused on sustainability and accountability. Below is detailed information on the pricing for affiliate trading services and supporting service packages.
Updated price list for affiliate trading services with the most detailed information.
To help businesses gain a clearer understanding of related party transaction documentation costs, Below is a reference price list for related-party transaction services for 2026, categorized by common service types in the market. The fees are based on the actual scope of work as stipulated in Decree 132/2020/ND-CP, including preparation of related-party transaction declarations, creation of local files and master files, as well as comprehensive service packages and support when businesses interact with tax authorities. The table below will help businesses easily compare the scope of work and choose a service package suitable for their related-party transaction scale.
| Type of service | Implementation content | Estimated fee (VND) |
| Review and Declaration | Review existing related-party transactions, prepare Form 01 declaration according to Decree 132. Advise on weaknesses in the current documentation system. | 20,000,000 – 40,000,000 |
| Local File | Prepare a complete portfolio with three chapters: General Information, Industry Analysis, and Related Party Analysis. Include a valuation strategy. | 70,000,000 – 130,000,000 |
| Corporate profile (Master File) | In-depth analysis of global corporate structure, value chains, and intangible assets. Mandatory for companies that are members of multinational corporations. | 80,000,000 – 150,000,000 |
| Comprehensive package | Local File, Master File, and Country-by-Country Report, Declaration | 180,000,000 – 350,000,000 |
| Support for tax inspectors | Draft explanatory documents and work directly with the inspection team to defend the pricing method. | Contact MAN – Master Accountant Network |
Note: The above price list for related-party transaction services is for reference only, intended to help businesses visualize the cost range when preparing related-party transaction documentation. In reality, fees may vary depending on several factors such as revenue size, number of related-party transactions, complexity of corporate structure, benchmarking data analysis requirements, and the scope of documentation required as stipulated in Decree 132/2020/ND-CP.
To receive the most detailed and accurate transfer pricing service quote for each specific case, businesses should contact MAN – Master Accountant Network directly for an initial risk assessment, scope of work determination, and quotation tailored to their specific operations. This ensures that the transfer pricing documentation is complete, well-explained to the tax authorities, and minimizes the risk of tax audits later on.
Pricing table for industry benchmarking data.
MAN is committed to using data from Orbis (Bureau van Dijk), the gold standard in transfer pricing auditing used by international organizations and the General Department of Taxation of Vietnam. This data is suitable for all business sectors.
| Benchmarking category | Data characteristics | Fee (VNĐ/Set) |
| Local data | Filtering from over 100,000 businesses in Vietnam, we selected 10-15 of the most reliable samples. | 30,000,000 – 50,000,000 |
| Regional data | This method is used when there isn't enough data from Vietnam for comparison. Filter from similar countries (Thailand, Singapore, Malaysia, etc.). | 60,000,000 – 90,000,000 |
| Compare interest rates | Use Bloomberg/Reuters data to demonstrate that internal borrowing rates are in line with market conditions. | 35,000,000 – 55,000,000 |
| Comparing licensing fees | Analyze similar intangible asset transactions globally. | 50,000,000 – 80,000,000 |
Note: The industry benchmarking data fee table above is for reference only, to give businesses an overview of costs when building transfer pricing documentation.
Why do MAN's fees accurately reflect the value of the service?
When evaluating the pricing of related-party transaction services, businesses need to look at the core values that constitute credibility and professionalism.
- Expertise: The team preparing the business documentation consists of experts in the field of transfer pricing and has previously worked in senior tax advisory positions at the Big 4 firms. MAN – Master Accountant Network has a thorough understanding not only of Vietnamese law but also of OECD guidelines.
- Practical experience: MAN has experience defending such records against inspection teams. We know exactly which weaknesses tax officials tend to focus on when protecting a business.
- Authentic data: Owning expensive data accounts allows us to provide "telling" and absolutely legally binding figures.
- Commitment to ongoing support: We don't end the contract upon handover of documents. This commitment is most evident when the business receives an inspection notice. MAN will assist in explaining every detail in the compiled documents.
Professional transfer pricing service implementation process
To ensure the highest quality commensurate with the pricing of the affiliate transaction services provided, MAN – Msster Accountant Network's process includes:
Phase 1: Initial Risk Assessment
This is the most important preliminary step for experts to gain an overview of the company's compliance status, including the following key activities:
- Gather information about the corporate structure and the transactions that have occurred.
- Identify “red” risks (such as continuous losses while continuing to expand production).
Phase 2: FAR (Functions, Assets, Risks) Analysis
After defining the scope, MAN conducts in-depth analysis to break down the economic nature of each unit in the supply chain:
- Interviewing operational departments is crucial to determining the company's actual operations, ownership, and risks. This is the most important step in choosing a valuation methodology.
Phase 3: Finding comparative data (Benchmarking)
Based on the FAR analysis results, MAN experts will use screening algorithms on international data systems to find the most similar objects:
- Perform qualitative and quantitative screening steps based on international databases.
- Calculate the standard profit margin (Quartile 1 to Quartile 3).
Phase 4: Completing the application
Based on the data and arguments we have developed, we have structured them into a complete set of documents, ensuring high legal and logical validity:
- Write a detailed report in multiple languages such as English, Chinese, and Korean (if needed).
- Ensure that the economic arguments are consistent between the Local File and the Master File.
Phase 5: Storage and Updates
Finally, the expert will hand over the information and advise the business on how to manage records to prepare for future inspections.
- Guide businesses to store records in accordance with legal regulations (for at least 10 years).
Conclude
Choosing a service provider based solely on the cheapest related-party transaction service price list is often the start of an unnecessary tax crisis. For multinational corporations, legal stability and transparency in tax compliance are core foundations for sustainable growth in the Vietnamese market.
The 2026 tax season is fast approaching. Don't let the risk of being overcharged or facing significantly higher penalties for tax evasion impact your company's cash flow and reputation. Proactively protect your interests and optimize your tax obligations today by choosing a comprehensive solution. Contact us for advice on a safe valuation process and a detailed quote.
Contact MAN – Master Accountant Network to receive support from leading experts in building the safest transfer pricing strategy!
Contact information MAN – Master Accountant Network
- Address: No. 19A, Street 43, Tan Thuan Ward, Ho Chi Minh City
- Mobile/Zalo: 0903 963 163 – 0903 428 622
- Email: man@man.net.vn
Content production by: Mr. Le Hoang Tuyen – Founder & CEO MAN – Master Accountant Network, Vietnamese CPA Auditor with over 30 years of experience in Accounting, Auditing and Financial Consulting.
Frequently Asked Questions about the pricing of related party transactions
Below is a summary of the most common questions businesses have when considering budgeting for transfer pricing compliance:
Why is there such a large difference in the pricing of related-party transaction services (ranging from tens of millions to hundreds of millions of Vietnamese dong)?
Pricing reflects data quality and analytical depth. Low-cost providers often skip the actual FAR analysis step and use unlicensed comparative data, leading to filings that are easily rejected during audits. Meanwhile, premium services include the cost of purchasing international data (such as Orbis) and the expertise of experienced consultants to defend your case before the General Department of Taxation.
Is the cost of filing for a loss-making business cheaper than for a profit-making business?
The reality is the opposite. Loss-making businesses are often under higher scrutiny by tax authorities. Explaining why a business is operating and transacting with related parties while incurring losses requires experts to spend more time on economic reasoning and searching for specific data. Therefore, service fees may be higher to ensure legal compliance.
Does the affiliate trading service price list include the benchmarking data purchase fee?
Typically, reputable consulting firms will provide a comprehensive quote that includes access to and data extraction from large systems. However, businesses should clarify this in the contract to avoid additional fees that may arise when expanding the scope of comparison to the ASEAN region or globally.
Is it possible to save costs by preparing the application myself and only hiring a review service?
It's possible, but the risk is very high if the internal accounting team lacks in-depth knowledge of the Quartile method and how to select independent comparative samples. The review cost is usually only 30-40% of the cost of preparing a new report, but if the self-prepared report is too weak, the consulting firm may require it to be redone from scratch to ensure its accountability.
How are the costs of assisting with tax audits calculated?
Depending on the agreement, this fee may be calculated based on actual working hours, a fixed fee per inspection, or a fee based on the amount of tax protection collected. Hiring a partner to prepare the documentation always helps businesses optimize this cost more effectively than hiring a completely new third party once the inspection has begun.